Is annual ethics training a requirement for the DON Commercial Purchase Card Program?
Yes, Cardholders and Approving Officials who make purchases in excess of $100,000 per fiscal year must complete Form OGE 450 and, therefore, are required to take local annual ethics training. Cardholders and AOs who do not exceed these respective $100,000 per fiscal year thresholds may still be required to complete Form OGE 450 and take local annual ethics training if required by their supervisor when, in the supervisor’s judgment, the cardholder or AO otherwise has duties involving the exercise of significant independent judgment over matters that will have a substantial impact on the integrity of DON operations or relationships with non-Federal entities, or to avoid actual or apparent conflicts of interest.
